IR 05000272/2022004
| ML23031A035 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/31/2023 |
| From: | Brice Bickett Division of Operating Reactors |
| To: | Carr E Public Service Enterprise Group |
| References | |
| IR 2022004 | |
| Download: ML23031A035 (1) | |
Text
January 31, 2023
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000272/2022004 AND 05000311/2022004
Dear Eric Carr:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Salem Nuclear Generating Station Units 1 and 2. On January 26, 2023, the NRC inspectors discussed the results of this inspection with Dave Sharbaugh, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the severity level of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Salem Nuclear Generating Station Units 1 and 2.
The inspection report describes a Severity Level IV violation. We determined that additional follow-up using Inspection Procedure 92702, Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders was not warranted because the violation can be appropriately sampled using baseline inspection resources. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Brice A. Bickett, Chief Projects Branch 3 Division of Operating Reactor Safety
Docket Nos. 05000272 and 05000311 License Nos. DPR-70 and DPR-75
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000272 and 05000311
License Numbers:
Report Numbers:
05000272/2022004 and 05000311/2022004
Enterprise Identifier: I-2022-004-0038
Licensee:
Facility:
Salem Nuclear Generating Station
Location:
Hancocks Bridge, NJ
Inspection Dates:
October 1, 2022 to December 31, 2022
Inspectors:
J. Dolecki, Senior Resident Inspector
E. Garcia, Resident Inspector
N. Mentzer, Resident Inspector
P. Finney, Senior Project Engineer
K. Mangan, Senior Reactor Inspector
S. Obadina, Resident Inspector
P. Ott, Operations Engineer
S. Wilson, Senior Health Physicist
Approved By:
Brice A. Bickett, Chief
Projects Branch 3
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Salem Nuclear Generating Station Units and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Turbine Driven Auxiliary Feed Water (TDAFW) Room Cooler Changes Required License Amendment Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000272,05000311/2022004-01 Open/Closed Not Applicable 71152A The inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR 50.59,
Changes, Tests, and Experiments, because PSEG incorrectly concluded a change to the plant was not adverse and could be made without prior NRC approval. Specifically, PSEG revised procedure S1(S2). OP-SO.SW-0005, Service Water System Operation," by removing the requirement to declare TDAFW inoperable when room cooler, VHE36, was removed from service. The inspectors determined that compliance with 10 CFR 50.59 would not allow this change without obtaining a license amendment because the change affected the Salem Unit 1 and 2 technical specifications (TSs), and the change resulted in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC)important to safety previously evaluated in the updated final safety analysis report (UFSAR).
Additional Tracking Items
None.
PLANT STATUS
On October 1, 2022, Unit 1 reduced power to approximately 66 percent to repair the main bus duct cooling system. On October 2, 2022, Unit 1 was returned to rated thermal power. Unit 1 operated at or near rated thermal power for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power. On December 24, 2022, an unplanned, Unit 2 automatic trip occurred due to inadvertent safety injection actuation caused by steam generator steamline pressure differential pressure indications. The unit was restarted and entered mode 2 on December 24, 2022, and was returned to rated thermal power on December 26, 2022. Unit 2 remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures in November 2022
External Flooding (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding, on December 28 through December 29, 2022
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, service water bay #2 with work being performed on redundant service water bay, on October 3, 2022
- (2) Unit 1, emergency diesel fuel oil subsystem during 12 diesel fuel oil transfer pump inservice testing, on October 11, 2022
- (3) Unit 1 and 2, FLEX 460V control centers prior to portable diesel and cable testing, on October 19, 2022
- (4) Unit 1, 12 chemical and volume control (CVCS) subsystem due to upcoming 11 CVCS work window, on November 8, 2022
Complete Walkdown (IP Section 03.02) (1 Sample)
- (1) Unit 2, chemical and volume control system, on November 29, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 2, auxiliary building elevation 84', 460V switchgear rooms and corridors, Fire Area FP-SA-2541, on October 26, 2022
- (2) Unit 2, auxiliary building elevation 64', 4160V switchgear area and 2C battery room, Fire Area FP-SA-2531, on October 26, 2022
- (3) Unit 1, turbine generator and service building elevation 88, FP-SA-1141, on December 1, 2022
- (4) Unit 2, turbine generator and service building elevation 88, FP-SA-2141, on December 1, 2022
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 2, non-radiologically controlled area of the auxiliary building on the 84' elevation, 230V/460V switchgear room, on November 29, 2022
- (2) Unit 1, chiller room electrical penetration area, on November 30, 2022
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator requalification exam results for the annual operating exam and biennial written exam completed on November 8, 2022.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed Unit 1 and 2 operations personnel during various activities, on November 9, December 5, and December 12, 2022
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed a simulator evaluation that included a stuck open atmospheric dump valve, stuck closed turbine governor valve, reactor trip due to dropped control rods, and a loss of coolant accident, on November 16, 2022
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (4 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Units 1 and 2, fire protection dampers following short circuit identified during testing, on October 3, 2022
- (2) Unit 1, nuclear instrumentation system, on October 18, 2022
- (3) Units 1 and 2, vital instrument bus inverters, due to failure of 1D vital instrument bus modulation index control card, on November 22, 2022
- (4) Units 1 and 2, gas turbine/jet engine due to interim abandonment, on December 22, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Units 1 and 2, emergency diesel generator fuel oil system, on December 29, 2022
Aging Management (IP Section 03.03) (1 Sample)
The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:
- (1) Units 1 and 2, auxiliary building below grade walls in the 4160V switchgear rooms due to cracking and ground water intrusion, on November 2, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1, emergent work on main bus duct cooling fan requiring downpower to approximately 66 percent reactor power, on October 1, 2022 (WO 60155019)
- (2) Unit 2, elevated risk work on 22 control rod drive motor-generator set due to oscillating overcurrent relay, during week of October 17, 2022 (WO 60155509)
- (3) Units 1 and 2, emergent work on security inverter due to a blown fuse and being placed on back-up power supply, on October 19, 2022 (WO 60155539)
- (4) Unit 1, elevated risk with 11 charging subsystem out of service to repair discharge check valve, 1CV47, on November 9, 2022 (WO 60153775)
- (5) Unit 1, emergent work on condenser air removal due to degraded vacuum and associated abnormal operating procedure entry, on November 15, 2022 (WO
===60155704)
- (6) Unit 2, emergent work on outer penetration building outside air supply dampers following inadvertent opening, from December 24 to 27, 2022 (WOs 60156058 and 60156219)
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01)===
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, rod control system due to rods stepping in late while in automatic control during downpower to repair main bus duct cooling system, on October 12, 2022 (notification (NOTF) 20917626)
- (2) Unit 1, emergency core cooling subsystem due to 11 charging pump discharge check valve, 1CV47, back leakage elevated, on November 18, 2022 (OEJ 70223983)
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Unit 2, 21 residual heat removal (RHR) pump motor preventive maintenance, on October 6, 2022 (WOs 40047849 and 50236937)
- (2) Unit 1, 11 charging pump discharge check valve, 1CV47, repair due to back leakage, on November 9, 2022 (WO 60153775)
- (3) Unit 1, 1A emergency diesel generator (EDG) after various periodic engine and supporting equipment maintenance, on November 28, 2022 (WOs 50239841 and
===50238122)
- (4) Unit 1, 1B emergency diesel generator following primary and secondary fuel filter replacement and identification of foreign material within secondary fuel filter, on December 5, 2022 (WO 50240531)
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01)===
- (1) Unit 1, S1.MD-FT.SEC-0001(Q), 1A Safeguards Equipment Control (SEC) sequencer surveillance test procedure, on November 2, 2022 (WO 50230485)
- (2) Unit 2, S2.IC-FT.RCP-0041(Q), "2PT-525 #22 Steam Generator Pressure Protection Channel II," on December 24, 2022 (WO 50239198)
- (3) Unit 2, S2.IC-FT.RCP-0041(Q), "2PT-546 #24 Steam Generator Pressure Protection Channel IV," on December 24, 2022 (WO 50240433)
- (4) Unit 2, S2.OP-ST.MS-0003(Q) "Steam-Line Isolation and Response Time Testing,"
on December 24, 2022 (WO 50237158)
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) Units 1 and 2, SH.OP-PT.FLX-0480(Z), "FLEX 480V Caterpillar Diesel Generators," on October 21, 2022 (WO 30370064)
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1, October 1, 2021 through September 30, 2022
- (2) Unit 2, October 1, 2021 through September 30, 2022
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1, October 1, 2021 through September 30, 2022
- (2) Unit 2, October 1, 2021 through September 30, 2022
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) October 1, 2021 through September 30, 2022
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) October 1, 2021 through September 30, 2022
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)10 CFR 50.59 evaluation for removal of room cooler requirement for turbine drive auxiliary feed water pump and associated actions for NCV
===05000272,05000311/2021004-03
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)===
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in backlog lists that might be indicative of a more significant safety issue.
71153 - Follow-up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) The inspectors evaluated an unplanned Unit 2 automatic trip due to inadvertent safety injection actuation caused by steam generator steamline pressure differential pressure indications, on December 24,
INSPECTION RESULTS
Turbine Driven Auxiliary Feed Water (TDAFW) Room Cooler Changes Required License Amendment Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000272,05000311/2022004-01 Open/Closed
Not Applicable 71152A The inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR 50.59, Changes, Tests, and Experiments, because PSEG incorrectly concluded that a change to the plant was not adverse and could be made without prior NRC approval. Specifically, PSEG revised procedure S1(S2). OP-SO.SW-0005, Service Water System Operation," by removing the requirement to declare TDAFW inoperable when room cooler, VHE36, was removed from service. The inspectors determined that compliance with 10 CFR 50.59 would not allow this change without obtaining a license amendment because the change affected the Salem Unit 1 and 2 TSs, and the change resulted in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the updated final safety analysis report (UFSAR).
Description:
The inspectors reviewed PSEG safety evaluation (SE) S2021-102 - Service Water System Operation - auxiliary feedwater (AFW) Pump Room Cooler Operability. The SE was performed to evaluate a change to procedure S1(S2). OP-SO.SW-0005. The change removed the requirement to declare TDAFW inoperable when VHE36 was out of service based on the SE and an associated technical evaluation conclusion that indicated the TDAFW room temperature would remain within safety-related SSC design limits without the cooler. The inspectors reviewed the evaluations that supported PSEGs view that the evaluations demonstrated that the room temperature up to two hours after pump initiation would remain below TDAFW operational limits. In the safety evaluation, PSEG staff stated that, after two hours, one of the two motor driven auxiliary feedwater subsystems (MDAFW)would be capable of providing adequate flow to the steam generators and, therefore, could replace the TDAFW pump if it failed due to high room temperature. As a result, PSEG determined the AFW TS limiting condition for operation (LCO) 3.7.1.2 was considered to be met and the procedure could be changed.
The inspectors reviewed the TS LCO for the AFW system. The TS LCO 3.7.1.2 states:
At least three independent steam generator auxiliary feedwater pumps and associated manual activation switches in the control room and flow paths shall be OPERABLE with:
a. Two feedwater pumps, each capable of being powered from separate vital busses, and b. One feedwater pump capable of being powered from an OPERABLE steam supply system.
The action statements for the LCO are:
With one auxiliary feedwater pump inoperable, restore the required auxiliary feedwater pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, with two auxiliary feedwater pumps inoperable be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and with three auxiliary feedwater pumps inoperable, immediately initiate corrective ACTION to restore at least one auxiliary feedwater pump to OPERABLE status as soon as possible.
The inspectors also reviewed the TS basis which states:
The OPERABILITY of the auxiliary feedwater system ensures that the Reactor Coolant System can be cooled down to less than 350 F from normal operating conditions in the event of a total loss of off-site power.
The inspectors questioned if the LCO requirement for three independent pumps and the requirement for a steam supply system to one pump turbine and two pump motors powered from separate vital busses would allow for the replacement of the TDAFW pump at two hours by a MDAFW pump. Specifically, the inspectors noted that the safety function - ensure the reactor can be cooled down to less than 350 F - was the same for all three pumps and there was no discussion of different mission times in the TS or associated bases for each pump.
The inspectors also noted that the LCO action statements do not have different requirements depending on which AFW pump is out of service. As a result, the inspectors questioned why it was appropriate to assume different mission times for each AFW pump.
The inspectors also reviewed UFSAR chapters 3, 5, and 10 and found several statements that described the mission time for AFW as 36-48 hours. The UFSAR states:
3.5.2.3.1 Backup Water Sources for Category I Water Storage Tanks Plant Shutdown Operating Procedures
The unit would be maintained in a hot shutdown condition until station operating personnel have assessed operating conditions, damage, and availability of water sources to attain cold shutdown.
5.5.7.3.4 Compliance with Branch Technical Position RSB 5-1
3. Capability to cooldown to shutdown assuming the most limiting single failure in less than
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Compliance is not required since the station can be maintained in a safe hot standby condition while any required manual actions are taken. The plant is capable of reaching RHR initiation conditions in approximately 36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, including time required to perform any manual action.
Cold Shutdown Scenario (Assuming Loss of All Non-seismic Category I Equipment)
The safe shutdown design basis of the Salem Units is hot standby. The station can be maintained in a safe hot standby condition while manual actions are taken to permit achievement of cold shutdown conditions following [a safe shutdown earthquake] with loss of offsite power. Under such conditions the station is capable of achieving RHR initiation conditions (approximately 350F, 375 psig) in approximately 36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />
10.4.7.2.4 Assumptions Potential Effects of Salt Water as a Long-Term Source of Auxiliary Feedwater
4. Following the loss of offsite power, the unit is held in hot standby for 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> at the time
cooldown is initiated. After 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of cooldown, the RHR system is placed in operation.
The inspectors concluded that the AFW system mission time was 36-48 hours and noted that changing the mission time of the TDAFW pump from 48 to two hours was a change to the facility that was not addressed in the SE. The inspectors review of the SE found that UFSAR chapters 3 and chapter 5 were not listed in the PSEG SE reference section and noted that PSEG did not change UFSAR statements related to mission time as part of the SE. During the inspection, PSEG staff stated that the AFW mission time was based on the system and was not train-specific. PSEG stated that only in the first two hours were three pumps required in order to meet system single failure criteria. After two hours, only two AFW pumps were required (due to reduction in reactor decay heat) to meet the AFW system safety function to maintain the reactor in a safe shutdown condition. However, the inspectors did not identify design or licensing documents that credited this two-pump configuration.
The inspectors reviewed the design requirements for the AFW system and found USFAR Section 10.4.7.2 stated that the AFW system consists of two safety-related 50 percent capacity motor-driven pumps and one safety-related 100 percent capacity TDAFW pump.
The AFW system is capable of functioning for extended periods, allowing time either to restore normal feedwater flow or to proceed with an orderly cooldown of the plant to design temperature of the RHR system. Additionally, the inspectors reviewed Branch Technical Position 10-1 - Auxiliary Feedwater System, which states that the AFW system should have at least two full-capacity, independent systems with diverse power sources. The inspectors found that that the Salem AFW system meets the power diversity requirements and that the two fully capable systems considered the TDAFW train one system and the two MDAFW trains as the other system. The diversity design and train distinction is also stated in TS 3.7.1.2 and described in UFSAR section 5.5.7.3.4:
The first subsystem is composed of two motor-driven pumps, each powered from a different emergency power train; the second subsystem incorporates a turbine driven pump which can receive motive steam from either of two steam generators.
The inspectors concluded that the AFW system mission time is 36-48 hours, diverse AFW sub-trains are required, and each sub-train is credited to be capable of responding for the AFW system mission time. The inspectors also determined that the applicable TS LCO is train-specific and requires independent AFW pump trains. Additionally, TS action statements for inoperable pumps were developed based on the remaining pumps' capability to meet the AFW system mission time. As a result, the inspectors concluded that PSEG's evaluation conclusions were not supported as to a two-hour TDAFW pump design basis mission time or that the AFW safety function could then be met by MDAFW pumps. The inspectors noted multiple USFAR statements that would need to be changed, that were not proposed to be changed in the SE, if this were the case. The inspectors also concluded that TSs would require revision to reflect in the AFW LCO and Action Statements that the two subsystems were not both capable of performing the AFW function as assumed for the stated design basis mission time. As a result, the licensee was required to obtain a license amendment prior to making this change.
Corrective Actions: Following identification of the issue, PSEG entered the issue into the corrective action program and restored the procedure requirement.
Corrective Action References: Notification 20924239
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency. The inspectors determined that the procedure was changed after approving a 10 CFR 50.59 safety evaluation. However, after the change to the procedure was implemented, the room cooler was not taken out of service prior to this inspection so the TDAFW pump mission time was maintained as assumed in the design basis. Therefore, the performance deficiency significance would be considered minor.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: In accordance with NRC Enforcement Manual, Section 2.1.3, Enforcement of 10 CFR 50.59 and Related FSAR Violations, Section D.5.a, the inspectors determined this violation is best categorized as Severity Level IV because the change required prior Commission review and approval, and the licensee failed to obtain Commission approval. In reaching this conclusion, the inspectors determined that the violation is similar to NRC Enforcement Manual, Appendix E, Examples of Minor Violations - Minor Changes to Requirements because the change required prior NRC review and approval. The violation is categorized at Severity Level IV because the safety significance of the change would not be assessed as greater than Green under the ROP.
Violation: 10 CFR 50.59(c)(1) requires, in part, that a licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedures as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to 10 CFR 50.90 only if:
- (i) A change to the technical specifications incorporated in the license is not required.
10 CFR 50.59(c)(2) requires, in part, that a licensee shall obtain a license amendment pursuant to Sec. 50.90 prior to implementing a proposed change if the change would:
- (ii) Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated).
Contrary to the above, on April 4, 2022 through September 22, 2022, PSEG had an approved 10 CFR 50.59 safety evaluation allowing the implementation of a change to the service water procedure which should have required a license amendment pursuant to 10 CFR 50.90. Specifically, the SE evaluation inappropriately determined a license amendment was not required based on crediting the operation of the MDAFW pump to provide the AFW safety function following the accepted failure of the TDAFW during a design basis event. However, this assumption would require a change to LCO 3.7.1.2 and its associated actions statements because the LCO independence and diversity requirements were no longer met. Further, the removal of VHE36 room cooler as a support system for the TDAFW pump resulted in more than a minimal increase in the likelihood of occurrence of a malfunction of the TDAFW pump because the SE evaluation determined the TDAFW pump room temperature would remain below operational limits for two hours of operation post-event when the design and licensing basis credited TDAFW operation for the mission time (36-48 hours) of the AFW system.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Observation: Semi-Annual Trend Review 71152S The inspectors reviewed a sample of issues and items tracked within PSEGs corrective action program (CAP) and other programs to identify potential trends in resolving deficiencies associated with SSCs. Inspectors focused this review on CAP maintenance backlog lists. As a result of this review, the inspectors identified a trend in long-standing significance level 2 or 3 issues (conditions adverse to quality (CAQ) or regulatory compliance (CARC)) that have remained unaddressed within their backlog list.
The combination of LS-AA-120, Issue Identification and Screening Process, and LS-AA-125, Corrective Action Program, define PSEGs CAP and are used to identify CAQs and CARCs. PSEG uses these procedures in conjunction with WC-AA-106, Work Screening and Processing, to correct CAQs and CARCs. As such, the approved processes within LS-AA-125 and WC-AA-106 must have process controls that are sufficiently robust to drive completion of corrective actions as intended and within appropriate time constraints. In accordance with WC-AA-106, work priority designations ranging from 1 to 5 are to be assigned by the station ownership committee based on the component and/or work significance. For example, priority 1 is emergency work that is to be worked immediately and around the clock while priority 5 is routine work that is to be worked routinely (i.e., with a target date greater than 20 weeks) during the normal scheduling process (i.e., typically the next functional equipment group window within the E-26 window).
Based on a sample of outstanding NOTFs, the inspector identified examples of long-standing SSC-related CAQ or CARC NOTFs within their backlog list. Specifically, to name a few, inspectors identified unaddressed deficiencies related to the 12 diesel fuel oil storage tank inlet valves identified in April 2020 (NOTFs 20851063 and 20866072), service water inlet valves to charging pump room coolers identified in August 2019 (NOTFs 20830597 and 20876129), and the control volume and chemical hold-up tank bypass valve identified in October 2017 (NOTF 20776379).
Based on the above information, discussions with PSEG staff, and work management and CAP procedure reviews, inspectors identified that PSEGs process permits CAQs and CARCs to be left unaddressed because the work control process in accordance with WC-AA-106 does not drive prompt completion of corrective actions. Specifically, the work prioritization process established within WC-AA-106 does not consider the significance level in the priority designation determination and, as a result, CAQs and CARCs can be assigned priority level 5 (non-priority). Inspectors determined that timely completion of corrective actions for CAQs and CARCs with priority level 5 designations may be vulnerable as evidenced by the examples listed above. PSEG generated NOTF 20924547 to capture this observation and evaluate applicable procedures to ensure CAQs and CARCs are being addressed appropriately.
The NRC inspectors did not identify any findings or violations of more than minor significance.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 26, 2023, the inspectors presented the integrated inspection results to Dave Sharbaugh, Site Vice President, and other members of the licensee staff.
THIRD PARTY REVIEWS
Inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the inspection period.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
20924765
Entered SC.OP-AB.ZZ-0001 for high river level of 96 feet
2/23/2022
Miscellaneous
SC.OP-PT.ZZ-
0002
Station preparations for seasonal conditions
Miscellaneous
Seasonal readiness
Procedures
SC.OP-AB.ZZ-
0001(Q)
Adverse Environmental Conditions
Work Orders
and 30366190 for
SC.MD-GP.ZZ-
0178
Station preparations for winter - electrical
Work Orders
and 30361336
BRE requirements
Work Orders
WO 30362708 for
SH.FP-TI.FP-
0001
Freeze prevention and winter readiness of fire protection
systems
Work Orders
WO 30363195 for
SC.MD-GP.ZZ-
0001
Station preparations for winter - mechanical
Work Orders
Winter readiness tracking order
Corrective Action
Documents
20866072
Collar on 12DF29 valve between hand wheel and yoke
appears to be backing out
11/17/2020
Corrective Action
Documents
20885228
Corrosion on battery positive terminal in 1FLXE9 portable
diesel generator
09/30/2021
Corrective Action
Documents
20918302
Vibration box used during 12 DFOTP IST was reading
overload
10/11/2022
Drawings
205228
Chemical and volume control, sheet 2
Drawings
205228
Chemical and volume control, sheet 3
Drawings
205228, Sheet 1
Chemical and volume control, Sheet 1
Drawings
205242-SIMP,
sheet 1
Service water simplified P&ID
Drawings
205242-SIMP,
Service water simplified and nuclear header loads P&ID
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
sheet 2
Drawings
205249, Sheet 2
Fuel oil
Drawings
205328 Sheets 1,
2, and 3
Chemical and volume control mechanical
Drawings
205334, Sheet 1
No. 2 Unit Safety Injection
Drawings
207530
Letdown and charging system
Drawings
606405, Sheet 1
Unit 1 460V FLEX control center one-line
Drawings
606405, Sheet 2
Unit 2 460V FLEX control center one-line
Drawings
S2.OP-ST.CVC-
0006
Inservice testing chemical and volume control valves modes
1-6
Procedures
S.OP-SO.CVC-
0002(Q)
Charging pump operation
Procedures
S1.OP-ST.ZZ-
0006
Inservice testing miscellaneous valves modes 1-6
Procedures
S2.OP-SO.CVC-
0002
Charging pump operation
Procedures
S2.OP-ST.CVC-
0001
Inservice testing - 21 boric acid transfer pump
Procedures
S2.OP-ST.CVC-
0003
Inservice testing - 21 charging pump
Procedures
S2.OP-ST.CVC-
0004
Inservice testing - 22 charging pump
Procedures
S2.OP-ST.CVC-
0005
Inservice testing - 23 charging pump
Procedures
S2.OP-ST.CVC-
0010
Borated water sources
Procedures
SC.OP-PM.FLX-
0001(Z)
FLEX standby equipment status checks
Miscellaneous
FP-SA-2531-F1
4160V Switchgear area and 2C battery room
Miscellaneous
FP-SA-2541-F1
460V Switchgear room
Corrective Action
Documents
Resulting from
Inspection
20922940,
20929241
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Evaluations
SA-PRA-012
Salem Generating Station PRA internal flood evaluation
Corrective Action
Documents
20912826
Fire damper testing improvements
08/25/2022
Corrective Action
Documents
20485573
License renewal structures monitoring program basis Unit 2
11/08/2010
Corrective Action
Documents
20819817
Restore S2 aux building elevation 64 north wall
2/26/2019
Corrective Action
Documents
20903450
1CAF204 alarm light lit on panel 796-1
04/21/2022
Corrective Action
Documents
20908659
D vital instrument bus unable to be maintained
06/27/2022
Corrective Action
Documents
20911502
1D vital instrument bus unlatched transfer switch
08/08/2022
Corrective Action
Documents
20912485
troubleshooting activities of 1D vital instrument bus not
recorded within SAP in accordance with troubleshooting
procedure
08/24/2022
Corrective Action
Documents
20912498
Received indication that S1ABF604 fire damper closed
08/24/2022
Corrective Action
Documents
20913241
1D vital instrument bus faulty modulating index card failure
analysis
08/30/2022
Corrective Action
Documents
20917673
Electrical short experienced during operability test of
2ABF501 fire damper
10/03/2022
Corrective Action
Documents
20924160
selector valve for secondary fuel filter 1DFE26 is leaking
2/05/2022
Corrective Action
Documents
20924238
FME in 1B EDG secondary fuel filter 1DFE26
2/05/2022
Corrective Action
Documents
80110129
LR-Salem structure monitoring action items
07/21/2022
Corrective Action
Documents
Resulting from
Inspection
20920419
Water chemistry analysis for Unit 1 auxiliary building 64
elevation south wall
11/17/2022
Corrective Action
20921260
Revision to condition monitoring of structures procedure to
11/17/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
specify timeline of report issuance
Corrective Action
Documents
Resulting from
Inspection
20925020
air leak from controller o-ring
2/27/2022
Corrective Action
Documents
Resulting from
Inspection
20925361
inverter PM change technical basis
01/10/2023
Corrective Action
Documents
Resulting from
Inspection
20925643
2-year inverter PM due date and grace
01/10/2023
Engineering
Evaluations
70197274
latched transfer of the 1B vital instrument bus uninterruptible
power supply
10/30/2017
Engineering
Evaluations
70199757-0010
equipment reliability evaluation 2D VIB inverter failure
04/02/2018
Engineering
Evaluations
225975
Review NOTF 20917673 to determine cause and perform
corrective actions
10/03/2022
Engineering
Evaluations
80124187-0020
PM change evaluation to extend inverter component
replacement frequency from 9 years to 12 years
01/10/2019
Miscellaneous
Commitment CM-
Structures monitoring program
Miscellaneous
Commitment CM-
Inspection of water-control structures
Miscellaneous
MRule function S-
13-F03
provide backup power from the Unit No. 3 gas turbine
06/23/2022
Miscellaneous
MRule function S-
GT-F01
provides emergency power to the group buses in the event of
a LOPA
06/23/2022
Miscellaneous
Performance-
Centered
Inverters > or = 5kVA
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Monitoring
Template
Procedures
S1/2.FP-
ST.FBR-0028(Q)
S1/2.FP-ST.FBR-0028(Q), Class 1 fire damper operability
test
Procedures
1/2-EOP-LOPA-1,
Sheet 2 of 5
Loss of All AC Power
Procedures
Condition monitoring of structures
Procedures
Implementation of the license renewal program
Procedures
OU-AA-300-001-
1001
"QV Independent Inspection Plan"
Procedures
S1/2.OP-
AB.LOOP-
0001(Q)
Loss of Off-Site Power
Work Orders
30156600
preventive maintenance - replace 115 VAC 1D vital
instrument bus 12 kVA UPS
10/22/2014
Work Orders
30344675
1B EDG Replace Secondary Fuel Filter
2/05/2022
Work Orders
60154646
1D vital instrument bus troubleshooting corrective
maintenance
08/25/2022
Work Orders
Maintenance Plan
PM029473
Monitor S1 auxiliary building
Work Orders
Maintenance Plan
PM029480
Monitor S2 auxiliary building
Corrective Action
Documents
20485560
License renewal structures monitoring program basis Unit 1
11/08/2010
Corrective Action
Documents
20918697
Identified 22 MG set overcurrent relay oscillating during
rounds
10/17/2022
Corrective Action
Documents
20920616
Degraded vacuum unit 1 main condenser
11/15/2022
Corrective Action
Documents
20924495
plenum damper next to 22 S/G pressure instrument tubing,
2CBV37, inadvertently open
2/24/2022
Corrective Action
20924496
plenum damper next to 24 S/G pressure instrument tubing,
2/24/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
2CBV38, inadvertently open
Drawings
205208, Sheet 1
Condenser Air Removal and Priming
Drawings
205208, Sheet 2
Condenser Air Removal and Priming
Miscellaneous
UFSAR section
Procedures
Temporary Configuration Changes
Procedures
S1.OP-
AB.COND-
0001(Q)
Corrective Action
Documents
20893420
1CV47 check valve back leakage
2/15/2021
Corrective Action
Documents
20917626
Rods stepping in late while in auto
10/01/2022
Engineering
Evaluations
223983-0020
Operable with engineering justification - 1CV47 check valve
back leakage
11/17/2022
Procedures
S.1.OP-ST.SJ-
0016(Q)
High head cold leg throttling valve flow balance verification
Work Orders
60153375
Performance of high head cold leg throttling valve flow
balance verification
05/08/2022
Corrective Action
Documents
20920669
Work order 60153775 could not be completed as written
because of 1CV81 leak-by
11/11/2022
Corrective Action
Documents
20924160
secondary fuel oil filter 1DFE26 leaking approximately 5 dpm
after filter replacement
2/05/2022
Corrective Action
Documents
20924238
foreign material (small piece of rubber) discovered in
secondary fuel oil filter 1DFE26
2/05/2022
Procedures
S2.OP-ST.RHR-
0001
Inservice testing - 21 residual heat removal pump
Procedures
SC.MD-PM.ZZ-
0052(Q)
Disassembly, inspection and assembly of velan swing check
valves
Work Orders
30344675
replacements of secondary fuel filter 1DFE26 on 1B EDG
2/04/2022
Corrective Action
Documents
20918989
1FLXE10 FLEX diesel generator needs fuel added (<900
gallons)
10/21/2022
Corrective Action
Documents
20919957
Portion of S1.MD-FT.SEC-0001 procedure not completed
11/02/2022
Corrective Action
20924976
S/G channel 2 failed high
2/24/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Corrective Action
Documents
20924985
S/G channel 4 drifting high
2/24/2022
Procedures
SH.OP-PT.FLX-
0480(Z)
FLEX 480V caterpillar diesel generators
71151
Engineering
Evaluations
224092-0100
11SW122 MSPI failure determination
07/06/2022
71151
Engineering
Evaluations
224092-0100
MSPI evaluation for 11SW122 failure to control in auto
07/06/2022
Corrective Action
Documents
Resulting from
Inspection
20924239
Engineering
Evaluations
S1(S2).OP-
SO.SW-0005
Service water system operation - AFW pump room cooler
operability
Revision 51
(54)
Corrective Action
Documents
20925047
Unit 2 trip and safety injection
2/24/2022
Drawings
205338, Sheet 1
Unit 2 Reactor Containment - Ventilation
Miscellaneous
Salem Unit 2 - RPS actuation critical and valid actuation of
auxiliary feedwater system
2/24/2022
Procedures
Unit Restart Review
14